Doc Ref: Orbis P11XX...Orbis Document Ref: P1147-04 Prepared By: Natalia Lopez Orbis Energy Limited...

Doc Ref: Orbis P11XX

EOGUKL OSPAR Public Statement 2015

Doc Ref: Orbis P1147

Page No: i

Document Control Page

Client: EOG Resources United Kingdom Limited

Report Title: EOGUKL OSPAR Public Statement

Date: 31/05/16

Orbis Document Ref: P1147-04

Prepared By: Natalia Lopez

Orbis Energy Limited

71- 75 Shelton Street

Covent Garden

London

WC2H 9JQ

E-mail: [email protected]

www.orbisltd.com

Revision Record:

DATE REV NO. DESCRIPTION PREPARED CHECKED APPROVED

19/05/16 D01 Draft NL FD SH

26/05/16 D02 for Client Review NL SH SH

31/05/16 C01 For Issue NL SH SH



Page No: ii

Table of Contents 1 Introduction ..............................................................................................................................................1

2 EOG Resources United Kingdom Limited ...................................................................................................1

3 Environmental Management System ........................................................................................................1

4 Overview of 2015 Activities ......................................................................................................................2

5 Summary of 2015 Environmental Performance .........................................................................................4

5.1 Conwy Platform.......................................................................................................................................4

5.2 Conwy Subsea Infrastructure ..................................................................................................................4

5.3 JB-115 Jack-up Barge ...............................................................................................................................5

5.4 Accidental Releases .................................................................................................................................5

6 Progress against 2015 EMS Objectives and Targets ...................................................................................6

7 Proposed 2016 Targets and Objectives .....................................................................................................8

Appendix A: Corporate Major Accident Prevention Policy ............................................................................. 10

Appendix B: EHS Policy .................................................................................................................................. 12



Page No: iii

Abbreviations

CMAPP Corporate Major Accident Prevention Policy

DECC Department of Energy and Climate Change

EEMS Environmental Emissions Monitoring System

EHS Environmental, Health and Safety

ELBOC ENI Liverpool Bay Operating Company Limited

EMS Environmental Management System

EOGUKL EOG Resources United Kingdom Limited

MAT Master Application Template

NPAI Not-Permanently Attended Installation

OSPAR Oslo and Paris Commission

PETS Portal Environmental Tracking System

PON Petroleum Operations Notice

SOSREP Secretary of State’s Representative

UK United Kingdom

UKCS United Kingdom Continental Shelf



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1 Introduction Under OSPAR Recommendation 2003/5 to Promote the Use and Implementation of Environmental

Management Systems (EMS) by the Offshore Industry, the Department of Energy and Climate Change (DECC)

requires all operators of offshore installations to produce a Public Statement to report their environmental

performance. These Public Statements must be prepared on an annual basis (covering offshore installation

activities carried out during the previous calendar year), made available to the public and copied to DECC by

1st June of each year.

In accordance with this requirement, this document reports on the environmental performance of EOG

Resources United Kingdom Limited’s (hereafter referred to as EOGUKL) operated offshore activities in the

UKCS during 2015.

2 EOG Resources United Kingdom Limited EOGUKL is the UK subsidiary of EOG Resources Inc., one of the largest independent (non-integrated) oil and

natural gas companies in the United States, with substantial proven reserves in the United States, Canada,

offshore Trinidad, the United Kingdom and China.

The UK operation is headquartered in Guildford. Further information on the company is available from:

http://www.eogresources.com.

EOGUKL is the sole licence operator for Block 110/12a (Licence No. P.1476) in the East Irish Sea. EOGUKL

holds 100 per cent equity of this licence block. Licence P.1476 is the only EOGUKL operated licence held in

2015.

Block 110/12a contains the Conwy oil field, which EOGUKL began to develop in 2010, with the installation of

a single Not Permanently Attended Installation (NPAI) occurring in May 2012. The Conwy NPAI is tied back

to the ENI Liverpool Bay Operating Company Limited (ELBOC) operated Douglas Complex in Block 110/13 via

a 12 kilometre, 8-inch diameter production pipeline, which was also installed in 2012.

EOGUKL is the Production Licence Operator (and Installation, Well and Pipeline Operator) of the Conwy

Development.

3 Environmental Management System EOGUKL operates under an integrated Environmental, Health and Safety (EHS) Management System, which

has been developed to be consistent with existing international and national models for health, safety and

environmental management (e.g. ISO14001, OHSAS 18001, HSG (65), BS 8800).

The management process is structured around the plan, do, assess and adjust process, with a feedback loop

to assure continual improvement in performance, as illustrated in Figure 3.1. This system provides the

mechanism to implement EOGUKL standards relevant throughout the business lifecycle from acquisition of

new licences and acreage through to decommissioning and divestiture.

The key steps in this process can be described as follows:

1. Policies, Standards and Expectations

The system is driven by the Corporate Major Accident Prevention Policy (CMAPP) and the EHS Policy (copies

of which have been provided in Appendices A and B), which sets out the Company’s expectations and

commitments to the prevention of major accident hazards and EHS performance. The policies provide a

framework for establishing performance goals, from which targets are established.

2. Organise

Planning during the annual budget process defines work activities and resource needs for the upcoming year.

EHS roles and responsibilities are clearly defined. Commitment to EHS is visibly demonstrated through

defined internal and external communication networks. Personnel have the competence and training to

meet their responsibilities.



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3. Plan

All potential hazards and risks associated with planned activities are identified, assessed and control

measures identified. Plans to respond to emergencies and unforeseen events are in place.

4. Do

Guidelines, bridging/interface documents and local operating procedures are established so that risks are

properly managed and the Company’s expectations and standards are delivered. Competent contractors are

selected and managed. Significant changes made to the organisation, plant / equipment, guidelines and

procedures are also subject to this risk review as part of the change management process.

5. Assess and Adjust

Routine monitoring is undertaken to assess EHS performance. Procedures for reporting and investigating

incidents and non-compliances are in place. Audits, inspections and reviews are undertaken to check the

effective functioning and continued suitability of the management system. Performance against standards is

reported and reviewed and areas for improvement identified. Lessons learned and results from the audit,

inspection and review process are fed back into the system to enable continual improvement.

Figure 3.1. The EHS Management Framework

As required by OSPAR Recommendation 2003/5, EOGUKL’s Environmental Management System (EMS) has

been independently verified by Lloyds Register in October 2014. The EMS is scheduled to be re-verified in

October 2016.

4 Overview of 2015 Activities EOGUKL’s 2015 operated offshore activities comprised preparations for the start-up of production at the

Conwy field in Block 110/12a, which was targeted for Q1/Q2 2016 (Figure 4.1). This included operations at

the Conwy facilities and also EOGUKL operations at the ELBOC operated Douglas Complex host facility to

which Conwy will produce. The activities undertaken were as follows:

• Preparatory work on the Conwy NPAI – including commissioning of the Conwy pipelines and

maintenance and commissioning of process equipment on Conwy;



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• Preparatory work on Douglas – including commissioning of Conwy production reception facilities at

Conwy. This involved the use of the JB-115 jack-up crane and accommodation barge to allow EOGUKL

contracted personnel to complete works on the Douglas Complex.

Further details on activities associated with these operations and a summary of environmental performance

pertaining to these activities is discussed in Section 5.

Figure 4.1. Location of the Conwy Development and Associated Infrastructure



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5 Summary of 2015 Environmental Performance The potential environmental impacts associated with EOGUKL’s 2015 offshore activities include those

associated with preparatory work for the start-up of the production at the Conwy field including:

• Chemical use and discharges as regulated under The Offshore Chemical Regulations 2002 (as amended);

and

• Waste generated on the Conwy platform and the JB-115 jack-up barge.

The environmental performance data is therefore split into operations involving the Conwy infrastructure in

Table 5.1 and Table 5.2, and operations involving the EOGUKL contracted JB-115 jack-up barge in Table 5.3.

Of note is that normal power requirements for the Conwy field are met via a power cable from the ELBOC

operated Douglas Complex. Power generation requirements, and therefore associated atmospheric

emissions, from the Conwy NPAI are considered negligible.

5.1 Conwy Platform

Table 5.1. Environmental Performance Data from the Conwy Platform

Environmental Indicator Conwy Platform

Chemical Performance 1 Use (kg) Discharge (kg)

Gold (Use / Discharge) 100 100

Waste Type Reuse (t) Recycle (t) Waste to

Energy (t)

Incinerate

(t) Landfill (t) Other (t)

Special Waste (Group I) - 2.02 0.5 - - -

General Waste (Group II) - - - - - 0.42

Other (Group III) - - - - - -

Environmental Incidents

Chemical Release Number of Incidents 0

Hydrocarbon Release Number of Incidents 0

1 Only one chemical (cleaning detergent) was used on the Conwy platform during 2015.

5.2 Conwy Subsea Infrastructure

Data reported in Table 5.2 outlines the environmental performance related to subsea facilities. The subsea

infrastructure (comprising a production pipeline, water injection pipeline, condensate injection pipeline,

associated risers and a control/power/chemicals umbilical) associated with the Conwy field development was

installed in 2012.

During 2015 this subsea infrastructure was maintained in and prepared for use in production operations.

During this period the subsea infrastructure contain treated seawater (containing biocide chemicals)

primarily to prevent internal corrosion of the subsea infrastructure pending final commissioning prior to

start-up. Some production chemicals were introduced to the umbilical as a “first fill” in preparation for

production start-up

In 2015, DECC requested that the Conwy PON15C permit (PON15C/396) be closed with the remaining final

commissioning activities moved over to a Pipeline Operations permit on the new DECC Portal Environmental

Tracking System (PETS). The Pipeline Operations permit (DECC Ref: PLA/244) remained open throughout

2015 with an end date in 2016, coinciding with start-up of production, therefore chemical use and discharge

quantities associated with final commissioning activities will be reported via EEMS in 2016.



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As the PON15C permit ended in 2015, all chemical use and discharge from the pipeline installation and

commissioning activities covered by the PON15C were reported via EEMS in 2015. The EEMS chemical

performance reported in Table 5.2 therefore refers to chemical use and discharge under the PON15C

covering activities from 2012 to 2015.

Table 5.2. Environmental Performance Related to Subsea Facilities

Environmental Indicator Units Conwy Production Pipeline / Flowline /

Umbilical (PON15C/396)

Chemical Performance 1 Use Discharge

SUB (Use / Discharge) Kilogrammes 8,273 530

Gold (Use / Discharge) Kilogrammes 16,109.8 15,616.3

Silver (Use / Discharge) Kilogrammes 2.59 2.59

E (Use / Discharge) Kilogrammes 22,150.39 4,523.49


Chemical Release No. of Incidents 0

Hydrocarbon Release No. of Incidents 0

1 Chemical use and discharge has been grouped by Hazard Quotient Category / OCNS Group. Those chemicals with

substitution (SUB) warnings have been recorded separately and the amounts are not duplicated in the ranking categories.

5.3 JB-115 Jack-up Barge

The JB-115 jack-up barge was contracted by EOGUKL to support construction and commissioning work being

undertaken on the Douglas Complex. As the JB-115 barge was contracted by EOGUKL, environmental

reporting is undertaken by EOGUKL, despite it being at the ELBOC operated Douglas Complex. A summary of

the environmental performance from the JB-115 jack-up barge is provided in Table 5.3.

Table 5.3. Environmental Performance related to the JB115 Accommodation Unit

Environmental Indicator JB-115 Jack-up Barge

Waste Type Reuse (t) Recycle (t) Waste to

Energy (t)

Incinerate

(t) Landfill (t) Other (t)

Special Waste (Group I) - 16.143 4.2 3.255 0.04 -

General Waste (Group II) 7.93 54.847 - - 61.44 1.66

Other (Group III) - - - 0.077 - -


Chemical Release Number of Incidents 0

Hydrocarbon Release Number of Incidents 0

1 Includes all waste generated on the JB-115 jack-up barge whilst under contract by EOGUKL at the ELBOC operated

Douglas Complex.

5.4 Accidental Releases

Oil or chemical release incidents are reported to DECC in accordance with the electronic Petroleum

Operations Notice 1 (ePON1) system.

EOGUKL confirms that no oil or chemical release incidents occurred during their operated activities in 2015.



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6 Progress against 2015 EMS Objectives and Targets Based on the operated activities in 2015, EOGUKL set a number of EMS targets and objectives. The progress these against these targets and objectives is reported in

Table 6.1.

Table 6.1. Performance and Progress against EOGUKL’s 2015 EMS Objectives and Targets

Issue Objective Target Progress / Status

EHS

Management

System

Improve internal leadership

and communications.

Update EHS Policy. Complete – updated in May 2015.

Eight management site visits.

Completed – in excess of eight management site visits

to the Conwy NPAI, Douglas Complex and Offshore

Storage Installation.

Review organisation, training and competency

requirements for production.

Production organisation put in place and training

programme implemented to ensure competency.

Conduct Conwy pre-start-up environmental

awareness briefing. Deferred to 2016 as production start-up delayed.

Permits and consents –

Ensure full compliance.

Finalise and maintain Conwy Production

Consents Register. Complete.

Ensure risk assessments are

completed for major

activities.

Ensure start-up risks are reviewed and control

measures implemented.

Risk assessments undertaken as required for

construction and commissioning activities, and suitable

controls put in place.

Monitor EHS performance. Monthly reporting of EHS statistics and

incidents.

Monthly EHS statistics maintained for construction and

commissioning activities.

Review. Quarterly EHS and operations performance

review.

EHS and operations performance reviewed at monthly

management meetings.

Emergency

Response

Pre and post Conwy start-up

emergency response

exercises.

1 pre- and 1 post Conwy start-up emergency

response exercise (involving Douglas operator).

Pre start-up exercise completed in March 2015. Start-

up delayed, with post start-up SOSREP exercise

planned for May 2016.

8 Conwy platform EHS drills (focus on major

accident hazards).

Limited to performing 4 EHS drills due to NPAI visiting

constraints.

Emergency response

training.

Emergency response training for all personnel

(workshops and exercises prior to major

operational activity).

Complete – training up-to-date.



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Issue Objective Target Progress / Status

Spill response training. Sufficient number of personnel trained to DECC

Level 1, 2 and 3. Complete – training up-to-date.

Audits

Ensure all facilities and

operations are appropriately

audited.

Conwy Pre start-up EHS compliance audit. Start-up delayed. Target to be considered in 2016.

Conwy Platform EHS audit during production

operations. Start-up delayed. Target will be considered in 2016.

EHS Management System audit.

Complete – areas for improvement identified and

selected parts of EHS Management System will be

revised during 2016.

Environmental

Performance

Vented gas at Conwy

0.316 tonnes of gas vented per annum. Based on

maximum of six venting episodes per annum, at

1000 standard cubic feet of gas (28.3 m3 of gas) per

episode.

Start-up delayed. No gas vented during 2015.

Conwy Platform EHS audit. No oil or chemical spills. Achieved.

EHS Management System

audit.

Set baseline for chemical usage based on Q4

production and chemical use. Start-up delayed. Target will be considered in 2016.

Safety

Performance Accidents and incidents.

No Lost Time Injury. One Lost Time Injury

All incidents reported, investigated and findings

reported to workforce within 1 month. Incidents reported, investigated and findings reported.



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7 Proposed 2016 Targets and Objectives In 2016, EOGUKL’s UKCS operated activities are focussed on the start-up of production at the Conwy field,

which was achieved in March 2016. EOGUKL have identified a number of objectives and targets to aim for to

improve environmental performance in offshore activities in 2016; these are presented in Table 7.1.

Table 7.1. 2016 Targets and Objectives

Issue Objective Target

Leadership and

Communication

Improve internal

leadership and

communications

EHSMS Management Review – Suitability for Conwy

Production Operations (see also under “Audits and

Reviews” below)

Complete and issue CMAPP and update EHS Policy

6 Management site visits – senior managers to

operational sites

Review organisation and training and competency

requirements

Legislative and

Regulatory

Compliance

Permits and consents -

Ensure full compliance

Maintain Conwy Development consents register

Maintain Conwy Production Consents Register

Conwy Safety Case Update Conwy Safety Case to comply with OSDR

2015 and have it accepted by HSE

Conwy OPEP Update Conwy OPEP to comply with OSDR 2015

Contractor

Selection and

Management

Management and

monitoring of contractor

performance

Monitor through Audit Plan

Risk Assessment Ensure risk assessments

are competed for all

major activities.

Complete operational risk assessments as required

for completion of Douglas construction,

commissioning and start-up activities

Monitoring and

Incident

Reporting

Monitor EHS performance Maintain and report EHS statistics.

Incident reporting Ensure all EHS related incidents and accidents are

followed through to closure, with findings reported

to workforce within 1 month

Review Quarterly EHS and operations performance review

Safety

Performance

Incidents No lost time incidents

No reportable incidents under RIDDOR

Environmental

Performance

Vented gas at Conwy

platform

0.316 tonnes of gas vented per annum. (based on

maximum of 6 venting episodes per annum, at 1000

scf (28.3 m3) per episode)

Oil and chemical spills No oil or chemical spills

Offshore chemical use Set baseline for chemical usage based on Q1

production and chemical use

Emergency

Response

Emergency plans in place

and up to date

Update emergency response plan for Conwy

production operations

Emergency response

training

Emergency response training for all personnel

(workshops and exercises prior to major operational

activity)

Exercises held 1 per quarter (3 desktop, 1 full)

Offshore Conwy drills – at least 1 per quarter (focus

on major accident hazards, but to include 1 oil spill

scenario per OIM)



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Issue Objective Target

Oil spill response training Sufficient number of personnel trained to DECC

Level 1, 2 and 3

Reviews and

Audits

Ensure facilities and

operations are

appropriately reviewed

and audited

2016 Audit Plan – develop and implement

Conwy post start-up compliance audit

System reviews for

suitability

EHS MS Management Review – Suitability for Conwy

Production Operations (see also under “Leadership

and Communication” above)



Page No: 10

Appendix A: Corporate Major Accident Prevention Policy



Page No: 11



Page No: 12

Appendix B: EHS Policy

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